Adam R. CarlisleBlog Posts

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  • DOL, Recordkeeper Square Off in Confidentiality Disputes

    The DOL’s cybersecurity investigation into Alight Solutions, LLC, a retirement plan recordkeeper, has queued up court rulings on the reach of the DOL’s subpoena power that may have important implications for ERISA plan sponsors and their respective recordkeepers and service providers moving forward. First, the Seventh Circuit will weigh in on whether the district court... Continue Reading
    June 23, 2022
  • Allegedly Misclassified Independent Contractor Cannot Sue Under ERISA

    A California district court recently foreclosed a former independent contractor’s claims for benefits from ERISA-governed plans when it found that plaintiff was not a “participant” as defined by ERISA and thus did not have statutory standing to assert his ERISA claims. Alders v. YUM! Brands, Inc., No. 8:21-cv-01191-PSG-DFM (C.D. Cal. Feb. 1, 2022). After working... Continue Reading
    February 11, 2022
  • Eighth Circuit: District Court Improperly Resolved Factual Disputes on Summary Judgment in ERISA Benefits Case, But Error Harmless

    In Avenoso v. Reliance Standard Life Insurance Company, No. 21-1772, 2021 U.S. App. LEXIS 35264 (8th Cir. Nov. 30, 2021), the Eighth Circuit clarified its position in a circuit split over the proper judicial procedure for deciding ERISA benefits cases. The underlying case concerned the defendant’s denial of long-term disability benefits under an ERISA plan... Continue Reading
    December 7, 2021